PSGR is a not-for-profit, non-aligned charitable trust whose members are science and medical professionals. Since the recommendations of the Royal Commission on Genetic Modification to proceed with caution PSGR has maintained a watching brief on the scientific developments in genetic engineering (also referred to as genetic modification).

Genetically engineered organisms

This letter is to request that all Members of Parliament work cooperatively with all other Members of Parliament from across the political spectrum, in order to ensure a precautionary approach to the use of genetically engineered organisms. We ask this in the interest of protecting New Zealand's GE-free production and natural environment, and the economic advantage of a GE-free status for our export markets.

It is with concern that we again read proposals of using genetic engineering / modification technology outside of a laboratory. While New Zealand has worked soundly in this field in projects requiring the strictest confinement, there has been long-standing and strong academic and public opposition to approval of these novel organisms for release into any environment.

The basic problem inherent in all the discussion about genetic manipulation and gene editing (especially CRISPR) is that it is based on unscientifically naive exaggerations of what the technology actually achieves. Proponents talk about it being so precise and accurate and only making small changes that could have occurred as a result of ordinary germline mutations. This is fundamentally misleading. What they are talking about is the change which is targeted, but the targeted change is invariably accompanied by a very large number of other changes at similar sites in the DNA of the genome being altered. Although each of the changes may be small, genetic CRISPR is still a scattergun approach like earlier methods of genetic engineering. And the correlations between the sites affected by the scattergun are very likely to be of some genomic significance, which may eventually come to light at the population level after a long time. The effect of many changes are likely to remain undetectable using standard techniques of phenotyping because of their wide dispersal in the genome. Thus, genetic engineering and the recently acclaimed CRISPR are not much like the way enthusiasts describe them.

Once again the problems with gene drive technologies arise because of the disconnect between the engineering plan and biological/ecological reality. There is so little that is really known about the long or short term effects of gene-drive deployment that, in our opinion, it would be utter foolishness to unleash it on the environment, especially something as delicate as our native ecology. It is as if Hahn and Meitner[i], having discovered nuclear fission on the laboratory bench, told everyone to get busy designing and building a nuclear power plant.

Molecular biologists present inflated views of the worth of what they do in order to get research grants, start believing what they have said and then peddle it to the community as a way of justifying their funding. It all has to sound clever, smart, innovative, commercially viable, entrepreneurial and a solution to climate change, world hunger, antibiotic resistance, other medical problems, or ecological collapse. What is done is mostly scientifically and/or commercially speculative. Most of it does not work. The few magic bullets that are produced are dressed up so that their side effects are masked like the herbicide, glyphosate - and sold as complete solutions that are actually partial.

All molecular biological explanations are couched in terms of accepted concepts like gene that are not only problematic philosophically but also practically. We still have very little idea how complete genomes work. It is important to understand much more than the relationship between the genes and the features of individual organisms. We need to know what the effects of changes are on entire populations many generations down the line. That is what ecology depends on. It is likely there are huge chunks of ˜junk DNA" in the human genome, and in that of any other mammal, whose sudden loss would drive the species to extinction. None of that is ever considered in technological evaluations. As long as a proponent demonstrates the target effect and nothing else very evident, the world can be convinced that what is being done is safe and smart.

The main problem we are facing with biotechnology is that we are not, as a species, humble enough. Predictions of safety by proponents have been shown to be false, with short term monetary gain taking precedence over long term risks. We ask who, in ten years' time, would be held accountable for environmental damage. We repeat, once released, genetically engineered organisms can self-replicate and contaminate wild species.

Recently, talk has again suggested applying the technology for uses that would expose genetically engineered organisms in the New Zealand environment that are capable of replicating. As has been seen overseas, once released the novel DNA is irretrievable, will spread, and has negative results.

The request for your support to a precautionary approach reflects:

Evidence from two decades of commercial use of genetically engineered organisms overseas;

Improvements in society's understanding of complex natural systems, and knowledge in epigenetics;

PSGR urges caution be adopted by New Zealand's political leaders, in national and local government, for the regulation of such novel organisms outside of full containment.

Under current legislation there is no requirement for the Environmental Protection Authority (EPA) to apply the precautionary principle, or to require a bond, or to require proof of financial fitness from applicants. These are mechanisms that should encourage moderation of commercial risk-taking. Â This leaves New Zealand vulnerable to similar detrimental effects seen overseas, and at risk of repeating past mistakes on the scale of the destruction of 3000 genetically engineered sheep at Whakamaru in the Bay of Plenty.

This 2002 event resulted from the clinical failure of products outlined in Application Code GMF98001 made to the Environmental Risk Management Authority (ERMA), now the EPA, and the collapse of the overseas investment company running the experiment, leaving no funds for scientific bio-security tests or remediation at the site. At that time, ERMA admitted there was no monitoring at the Whakamaru farm and no recommendations in place for on-site monitoring. Requests from a range of interested parties for scientific analysis of the carcasses for future scientific benefit were denied.[ii]

Contradicting the need for precaution regarding genetically engineered organisms, there are calls from some commercial interests seeking to 'relax' rules, to reduce the EPA's oversight of experimental genetic engineering techniques. These calls are effectively encouraging the transfer of risk to the wider community and 'New Zealand Inc.' in order to advance interests in commercialising transgenic organisms, and leveraging Intellectual Property (IP) for their financial gain.

The US is the largest producer of transgenic crops; herbicide tolerant and Bacillus thuringiensis (Bt). Since mass commercialisation two decades ago, adoption has grown dramatically as can be seen from this graph produced by the Economic Research Service of the US Department of Agriculture.[iii]

Recent reports show US farmers are abandoning transgenic crops because of poor monetary returns. A media report says: Bold yellow signs from global trader Bunge Ltd are posted at US grain elevators barring 19 varieties of GMO corn and soybeans that lack approval in important markets.[iv]

A closer-to-home study will show how planting transgenic canola in Tasmania led to disaster with volunteer seedlings appearing many years after the cessation of plantings. The Moratorium that resulted was made indefinite in 2014 to protect its clean, green brand.[v][vi]

The evidence overseas from commercial release of such novel organisms also includes:

Increased incidence of tumour development shown in long-term feeding studies;

Genetic instability and unexpected effects from the processes of genetic engineering;

Contamination in the field, including by experimental and unauthorised test-crops emerging years after field-trials, even hundreds of miles away from the trial site, a result of horizontal gene transfer;

Extensive spread of weeds that have become resistant to genetically engineered DNA sequences as a result of in-field horizontal gene transfer[viii];

A new generation of transgenic crops being engineered to resist even more toxic chemicals such as 2,4-D responding to the growing failure of herbicides such as glyphosate, the active ingredient in Roundup used on Roundup Ready transgenic food crops;

These and other issues have raised local and international concern in scientific and civil-society communities. The transfer of risk that commercial release of transgenic organisms involves is indicated by the fact the insurance industry refuses cover for the potential damage of these organisms occurring, whether quickly, or slowly, or over an extended term.

Drawing on scientific, legal and other expertise, some New Zealand councils used the then standing Resource Management Act to consider in their Plans their responsibilities regarding precaution around genetically engineered organisms in the environment and on long-term land use. This process is ongoing with more Councils examining what steps they can take to protect their region.

Challenged in the Environment Court, these measures stand. They include a local level of oversight of transgenic organisms such as requiring bonds from commercial users of genetically engineered organisms to mitigate exposure of costs to ratepayers under 'socialised risk'. Â The measures respond to community and scientific concerns and may also help regional development for producers of safe, clean, premium-quality, GE-free foods for local and export markets; many of the latter demand 'GE Free' produce. In depth research showed Councils they needed to think long-term and for future generations, especially as the EPA loses jurisdiction at the point of approving a commercial release of a genetically engineered organism.

Federated Farmers have recently withdrawn their challenge to Northland Environment Court decisions giving Councils the right to oversight.

Thank you in advance for reading the information we have provided and for working with other Members of Parliament irrespective of political affiliation and responsibilities. Working together to ensure precaution in legislation is vital in responding to the proven risks from existing and new experimental techniques in the development of genetically engineered organisms.

Whatever your party's official stand on the transgenic debate, we urge you personally to recognise and support the need for precaution, and look forward to hearing from you.

An Overview of Genetic Modification in New Zealand, 1973-2013: The first forty years, a review of genetic engineering research in New Zealand by the independent McGuinness Institute, Wellington. It recommended that a moratorium on commercial transgenic release be instigated. http://mcguinnessinstitute.org/includes/download.aspx?ID=130247